Public consultation on the waste export cost recovery proposal is closed.
We asked for your feedback on the proposed ways to recover the costs of regulating waste exports.
How you had your say
The Cost Recovery consultation paper and survey was published on the department’s website on 4 November 2022. The consultation paper sought feedback from people on the proposal to implement application fees and export charges from 1 July 2023 to recover the costs of the waste exports scheme.
Respondents were asked questions relating to the proposal and could further expand on their input with a detailed submission. Respondents were further asked about the impact of the proposals on their business and the industry, which fee option and proposed levy model they preferred, future export forecasts and assumptions, export activity and, suggested alternate price structures or charge points.
We invited feedback from people across industry and affected sectors.
This included:
exporters of glass, plastic, tyres, paper and cardboard
export waste licence holders
recyclers
waste managers and traders
peak bodies and industry groups
state and territory environmental protection agencies
local governments
members of the public/Other interested parties.
We contacted you via email and invited you to provide a survey and/or a submission in response to the proposal to Have your say.
You gave feedback through:
an online survey
written submissions.
Who engaged
38 people or organisations participated in the review.
Survey
31 responded through our survey.
20 provided a submission via email or Have your say.
Have your say participants or representatives:
were from the plastic (16) followed by tyres (14) and paper and cardboard (12) industries.
were exporters (15) followed by recyclers (14) and waste managers (10)
were mostly from multiple states and territories (32%) or New South Wales (also 32%) followed by Victoria (18%).
What you said
Appropriateness of cost recovery for waste exports
Respondents raised concerns that cost recovery:
Could impact the financial viability of the sector and discourage investment in reprocessing facilities.
Would impose a cost burden disproportionately at the recycling and exporting end of the supply chain.
Could lead to increased landfilling if domestic recycling capacity is not available.
Could cause the export of price sensitive waste streams to become uncompetitive, or unviable leading to unwanted outcomes – landfilling, illegal disposal and stockpiling.
Was not appropriate when there was no local market alternative to export.
May undermine existing investments in recycling infrastructure.
Suggestions to improve the implementation of the cost recovery program.
Consideration of the timing until additional domestic reprocessing facilities are developed, and to allow policies around packaging targets to take effect, and impact local demand.
Levy Structure / rate
Concerns were raised around:
the potential for a per-tonne levy rate to disadvantage exporters of denser waste streams; and
impact exporter’s ability to compete with overseas suppliers with lower overheads.
Positive feedback was the potential for the levy to push the industry to onshore processing.
Fee structure / rate
Concerns raised were that the fee structure:
May stifle innovation, favour high volume producers and disadvantage small business.
May deter initial applicants for new waste streams in the future leading to increased landfill of previously exported waste.
Suggestions to improve the proposals were:
A different fee structure for applications for minor variations, to ensure traders remain commercially viable.
Developing a reduced fee structure for exports below a minimum annual quantity.
The majority of respondents (61%) preferred Option One: flat fee for each application type, over Option Two which was a base assessment fee and an additional fee for further assessment as required.
Compliance
Overall concerns on compliance:
The implementation of the cost recovery program could result in legitimate businesses paying for compliance, while non-compliant businesses avoid fees and levies.
The Department needs to maintain a strong focus on managing non-compliance.
Departmental Resourcing
Department processes should be reviewed to see if efficiencies can be found within the licencing program.
What happens next
Cost recovery for the waste exports scheme will commence from 1 July 2024 through the introduction of fees-for-service. Fees will be introduced using the design and rates set out in Option One of the consultation paper, preferred by the majority of respondents.
A cost recovery levy will not be introduced. There will be no charge imposed on consignments of waste exports.
Further information on fees and charges can be found at: Fees and charges to export regulated waste - DCCEEW